In re Hawkins, 463 B.R. 768 (Bkrtcy. W.D.Pa. 2012)

(plaintiff claimed that, under 11 U.S.C. § 523(a)(2)(A),  debtor’s obligation should not be discharged because loans were obtained under false pretenses; requirement for proof of claim is that debtor made a representation, but representations regarding the financial condition of the debtor are expressly excluded under the statute; plaintiff unable to prove representations that debtor’s business was profitable meet the remaining requirements; court held that, without more, a broken promise to repay does not satisfy the statutory requirements).